Both the CPR and the ESPR regulate the requirements for updating and maintaining the DPP, whereby the CPR takes precedence over the ESPR as a lex specialis, see also chapter 1.3.
Among other things, the following requirements are defined:
- The DPP and a back-up copy held by a third party must be accessible for a period of 25 years after the last product corresponding to the product type was placed on the market. The economic operator must make the DPP available for at least 10 years. If a longer period is specified, this must not result in disproportionately high costs and burdens for the economic operators. Particularly in the case of circular value chains, it can therefore be assumed that in the medium term, in conjunction with the obligation to keep a back-up copy, new service providers will come onto the market that will relieve small and medium-sized enterprises in particular of these obligations.
- The DPP shall remain in the Union even after the insolvency, liquidation or cessation of activity of the economic operator that issued the DPP. It fulfills the conditions laid down in the CPR with regard to the obligation to set up a back-up system.
- Additional conditions apply to the management of the required back-up copy of the DPP. In order to ensure the continuity of DPP access even in the event of the closure of a company, the resolver that forwards the permalink from the data carrier (e.g. QR code) to the current valid destination address of the DPP should theoretically not be economically linked to the distributor.
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